Training Course
Anti-Bribery Management System in Accordance with the International Standard ISO 37001:2025
Course Duration: One week (20 training hours)

Introduction

The Middle East is undergoing a shift in how it addresses integrity and anti-bribery. However, this shift varies from one country to another, and its impact at the level of companies themselves has so far been limited. According to Transparency International's 2025 Corruption Perceptions Index, the UAE scored 69 out of 100, Qatar 58, Saudi Arabia 57, Oman 52, Bahrain and Jordan 50 each, and Kuwait 46, while Iraq scored only 28 and Libya only 13. Palestine was not included in the 2025 edition because it did not meet the minimum number of sources required to calculate the index that year. An analysis by the Middle East Council on Global Affairs shows that the regional average score has practically not moved in five years, from 38.7 points in 2020 to only 38.8 points in 2025.

These figures do not only reflect national governance; they have a direct impact on the business environment within every organization. The World Bank estimates that businesses and individuals worldwide pay more than one trillion US dollars in bribes every year. PwC's Middle East Economic Crime Surveys have also shown that bribery and corruption are among the four most commonly reported types of economic crime in the region, and in one PwC survey, the proportion of organizations that had detected bribery or corruption internally within a two-year period reached 45%, compared with a lower global average over the same period.

It is precisely in this context that the International Organization for Standardization (ISO) issued, in February 2025, the new edition of the anti-bribery management system standard, ISO 37001:2025, replacing the 2016 edition. The new edition places clear emphasis on the responsibility of the governing body, integrates third-party risks, digital risks, and climate-related risks into risk assessment, and expands the requirements for due diligence and conflict-of-interest disclosure. Most importantly, this update is not optional in the medium term: 31 August 2026 has been set as the date after which no new certification or recertification may be issued against the 2016 edition, and 28 February 2027 has been set as the mandatory final deadline for transitioning all existing certificates to the 2025 edition, failing which the certificate will be suspended or withdrawn.

The practical problem facing many organizations in Jordan, the Gulf States, and Iraq is that they treat this matter as a paper-based procedure managed only at the time of audit, rather than as a living management system that informs day-to-day decisions in procurement, contracting, and relationships with agents and suppliers. The result is often nominal certificates that do not withstand a genuine audit, organizations caught off guard by the mandatory transition deadline without having actually begun updating their system, or teams that are not qualified to understand the leadership and organizational culture requirements that have become the core of the new edition. This course has been designed specifically to close this gap, with practical outcomes that take participants from understanding the text to being able to build and implement the system.

Why the Anti-Bribery Management System Course in Accordance with ISO 37001:2025 at The Only Solution for Training and Consulting?

In a subject such as anti-bribery, knowing the text of the standard is not enough. What an organization actually needs is a team that returns from the course able to begin implementation the next day, and that understands how bribery risks manifest specifically in the Arab business environment. The course has been designed on this basis, and this is what distinguishes it:

1.        Participants leave with working documents, not notes: Every day of the course ends with a practical output that participants build themselves: a gap analysis, a risk matrix, a due diligence template, a draft gifts and hospitality policy, and a 90-day action plan. These are not hypothetical exercises left behind in the training room, but drafts that can be customized and presented to management immediately upon returning to the organization, saving weeks of preparatory work.

2.        Content built on the realities of the region, not translated examples: Most training materials available in this field are adapted from Western environments that do not resemble the way business is conducted in our region. This course discusses the situations participants actually face: government contracts and tenders, commercial agents and distributors, customs clearance, and, most critically, the practical distinction between the culture of hospitality and courtesy deeply rooted in our societies and what constitutes an improper gift or benefit under the standard. This dividing line is exactly what confuses most organizations during implementation.

3.        A design directly linked to the mandatory transition deadline: The course is not a general explanation of the standard; it is built around a specific question: How can an organization transition to the 2025 edition before 28 February 2027 without its certificate being suspended or withdrawn? The content therefore focuses on the fundamental differences between the two editions and on prioritizing actions within the remaining time, rather than re-explaining what already-certified organizations know.

4.        Specialized trainers and training material updated to the new edition: The course is delivered by trainers specialized in compliance, governance, and anti-bribery systems, who combine a precise understanding of the standard's requirements with practical experience in implementing it within organizations, enabling them to answer participants' practical questions, not only theoretical ones. The training material has also been prepared entirely in accordance with ISO 37001:2025; it is not outdated material based on the 2016 edition with cosmetic amendments added. It reflects the latest requirements relating to governing body responsibility, third-party risks, and digital risks, as well as accreditation bodies' requirements for the transition period, ensuring that what participants learn is what they will actually be asked about during an audit.

Course Objectives

1.        Enable participants to analyze the gap between an existing system based on ISO 37001:2016 (or the absence of any system) and the requirements of the 2025 edition, and to build a realistic, phased update plan.

2.        Equip participants with the skills to design and implement ready-to-use practical tools: bribery risk assessment, third-party due diligence, and gifts and conflict-of-interest policies, in line with the nature of their business.

3.        Prepare participants to lead the internal audit process and prepare for the external audit within the mandatory timeframe ending on 28 February 2027, rather than treating this deadline as a later surprise.

Main Training Modules:

1^st Day: General Anti-Bribery Framework and the Transition from the 2016 to the 2025 Edition

• Context of the organization in the new edition: digital risks, climate-related risks, and third-party risks.
• The governing body and its expanded responsibility, and the anti-bribery compliance function and its independence.
• Practical exercise: Gap Analysis of an existing system based on the 2016 edition, identifying the fundamental gaps against the 2025 requirements.

2^nd Day: Risk Assessment and Due Diligence

• Methodology for assessing bribery risks according to the nature of the activity and the entity.
• Due diligence on suppliers, commercial agents, and Politically Exposed Persons (PEPs).
• Practical workshop: Building a complete risk matrix for a real-life case.

3^rd Day: Operational Controls and Policies

• The anti-bribery policy and the role of the independent compliance function within the organizational structure.
• Gifts, hospitality, and conflicts of interest: practical procedures and acceptable limits.
• Applied exercise: Drafting a complete gifts and hospitality policy for an organization.

4^th Day: Internal Audit and Incident Response

• Planning and conducting an internal audit in accordance with the new clauses of the standard.
• Internal reporting mechanisms, whistleblower protection, and preliminary investigation of incidents.
• Practical simulation (role-play): Handling an internal bribery report from the moment it is received until it is closed.

5^th Day: Transition Plan, Continual Improvement, and Preparation for the External Audit

• Building an organizational transition plan from the 2016 edition to the 2025 edition in line with the mandatory timeline.
• Management review and continual improvement as a permanent requirement, not a formal annual procedure.
• Practical exercise: Preparing a 90-day organizational action plan, presented by each participant or team.

Course Outcomes

• A precise, practical understanding of the requirements of ISO 37001:2025 and a clear distinction between them and the requirements of the 2016 edition.
• A risk matrix and a due diligence template ready to be customized and applied within the organization.
• A draft anti-bribery policy and a draft gifts and hospitality policy, ready for adoption after internal review.
• An organizational transition plan with a clear timeline that takes into account the mandatory deadline of 28 February 2027.
• A practical ability to lead an internal audit and prepare for an external audit by an accredited certification body.

Certificates:

Each participant who fulfils the course attendance and participation requirements will receive two certificates:

1.        A certificate of attendance issued by The Only Solution for Training and Consulting

2.        A certificate issued by Cambridge Training College Britain

The following is an essential clarification regarding the nature of these two certificates and the limits of reliance on them.

The Difference between a Course Attendance Certificate and a Management System Certification

The two certificates mentioned above are certificates of attendance and completion of a training program aimed at individuals, to demonstrate their understanding of the system and their ability to implement it. They are not a certification of the organization's anti-bribery management system in accordance with ISO 37001:2025.

Certification of the management system itself is granted only to an organization, not to an individual, and is issued only by an Accredited Certification Body following an actual on-site audit of the organization's system. Rather, our course participants form the foundation for implementing the system within their organizations, enabling those organizations to apply for and subsequently obtain certification.

The Only Solution for Training and Consulting is a training and consultancy provider, not a certification or accreditation body for management systems, and it neither holds nor claims any accreditation status from any national or international accreditation body. Furthermore, any certificate issued by the partner entity mentioned above is the sole responsibility of that entity with regard to how it describes itself and the degree of its official recognition. The institute neither confirms nor denies the accreditation status of that entity or its affiliation with any other academic institution bearing a similar name, and bears no responsibility for any use of that certificate by the participant or their organization for official purposes without prior verification of its degree of recognition by the relevant authority.

Requirements for an Organization to Obtain ISO 37001:2025 Certification from an Official Accredited Body

For organizations wishing to have their system officially certified against the standard, the internationally recognized path runs through a certification body accredited by an accreditation body that is a signatory to mutual recognition arrangements, and generally includes:

• Implementing a documented anti-bribery management system that is genuinely effective within the organization for a sufficient period before the audit, not merely theoretical documentation.
• Passing the Stage 1 audit (document and readiness review), followed by the Stage 2 audit (actual on-site audit).
• Closing any nonconformities identified by the audit team before the certificate is issued.
• Undergoing an annual surveillance audit and a recertification audit at least every three years, to maintain the validity of the certificate.
• For organizations already holding, a certificate issued against the 2016 edition: the certificate must be transitioned to the 2025 edition before the mandatory deadline of 28 February 2027, in accordance with accreditation bodies' requirements; otherwise, the certificate will be suspended or permanently withdrawn.

The official text of the standard and information on the new edition are available through the official website of the International Organization for Standardization.

To verify the validity of any certificate issued by a genuinely accredited certification body, the official global database is available. It should be noted that, as of early 2026, the International Accreditation Forum (IAF) merged into a broader entity called Global Accreditation Cooperation Incorporated, with the aforementioned database continuing to perform its verification function.

The Only Solution for Training and Consulting does not provide certification or accreditation services for management systems; its role is limited to building the knowledge and practical capabilities of individuals and teams in preparation for any certification path the organization later chooses with an accredited certification body of its choice.